ant. ) COMPLAINT Plaintiffs, J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, complaining of the defendant, Jeffrey Epstein, by their attorney Rosh D. Alger, herein allege: I. Plaintiff, J.P. Molyneux Studio, Ltd. is a corporation organized and existing under the laws of the State of New York and mainta

g for parties and counsel who are Filing Users and through the alternate method indicated below for any party or counsel who is not a Filing User. Rosh D. Alger, Esquire Rosh D. Alger, Esquire, LLC PMB 10 Royal Dane Mall #12 St. Thomas, VI 00802 Tel: Fax: via: CM/ECF MI Mail K I Fax K i Hand Delivery K

declarant before an officer authorized to administer oaths." Black's Law Dictionary (9th ed. 2009). The statement submitted by Plaintiffs' counsel Rosh D. Alger does not comply with V.I. Code Ann. tit. 5, §699 which also requires affirmations to be sworn statements of truth nor does it comply with Title 28

ren Indyke RE: Molyneux Complaint in the District Court of the Virgin Islands DATE: April 14, 2010 In connection with my request for you to send Rosh D. Alger a Rule 11 letter, you have asked me to provide you with some background relating to Jeffrey's claims against Mr. Molyneux which lead to the imprope

Case No.3:10-cv-00034 NOTICE OF MOTION COME NOW the Plaintiffs J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, by and through their counsel, Rosh D. Alger, and move this Court to exercise its discretion in the interests of justice by withholding its ruling on the Defendants' motion to dismiss, on the

parties is warranted pursuant to 28 U.S.C. § 2201. Defendants' motion should be denied. Dated: August 25, 2010 St. Thomas, U.S. Virgin Islands 5/ Rosh D. Alger Rosh D. Alger, Esq. Attorney for Plaintiffs J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux VI Bar No.932 PMB 10 Royal Dane Mall #12 St. Th